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Operation Choke Point has produced a spike in activity, with last week yielding two major settlements totaling over $6 million after a year of relative calm. As a result, G2 is reprising our 10 Steps guide for avoiding the unlawful activity that got the two defendant banks in trouble.

Recent headlines from CommerceWest Bank and Plaza Bank continue to underscore the need for a strong due diligence process when managing relationships with merchants and TPPPs. Although both cases involve complicity in fraud, they do highlight the consequences of being involved with such acts as well as how to avoid suspicions of impropriety. In the case of CommerceWest Bank, the pleading outlines several steps to ensure the bank is not abetting consumer fraud by taking precautions when working with payment processor customers including…

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